1999 Treasury Decisions

"Treasury Decisions" are either temporary or
final Regulations that have been approved by the Department of the Treasury after submission from the IRS. (Proposed regulations are not approved by the Treasury Dept.) Tax
Regulations are the IRS Commissioner's rules, for the application and administration of the Internal Revenue laws. The purpose of regulations is to provide taxpayers, their
representatives, and Service personnel with rules of general application so they may clearly understand the taxpayer's rights and duties under the law.

Regulations are promulgated by publishing in the Federal Register, and are also published in the weekly Internal Revenue Bulletin. All persons concerned are, by reason of
publication in the Federal Register, given notice of the official rules of the Department of the Treasury for the administration, application, and enforcement of the Internal Revenue laws.

Final regulations under section 743, 755, and 1017 of the Code provide guidance to partnerships and their partners concerning the optional adjustments to the basis of partnership property, the allocation of basis adjustments among partnership assets, and the computation of a partner's share of the adjusted basis of depreciable partnership property.

Final regulations under sections 2055 and 2056 of the Code relate to the effect of certain Administration expenses on the valuation of property that qualifies for the estate tax charitable or marital deduction. Rev. Ruls. 66-233, 73-98, 80-159, 93-48 obsoleted.

Final regulations under sections 2001, 2504, and 6501(c) of the Code relate to the valuation of prior gifts in determining estate and gift tax liability, and to the commencement of the period of limitations for assessing and collecting gift tax.

Final regulations under section 6011(e) of the Code generally require partnerships with more than 100 partners to file their partnership tax returns on magnetic media for tax years ending on or after December 31, 2000. However, electing large partnerships and partnerships using foreign addresses on their series 1065 forms are not required to file their returns on magnetic media for tax years ending before January 1, 2001.

Final regulations under section 3221 of the Code relate to the exception from the supplemental annuity tax with respect to employees covered by a supplemental pension plan established pursuant to a collective bargaining agreement and to a related excise tax with respect to employees for whom the exception applies.

Final, temporary, and proposed regulations implementing sections 672(f) and 643(f) of the Code relate to the application of the grantor trust rules to certain trusts established by foreign persons. A public hearing is scheduled for November 2, 1999.

This document removes regulations under section 954 of the Code relating to the treatment under subpart F of certain payments involving branches of a controlled foreign corporation (CFC) that are treated as separate entities for foreign tax purposes or partnerships in which CFCs are partners.

Proposed and temporary regulations under section 1397E of the Code relate to the method of ascertaining the qualified zone academy bond credit rate and provide reimbursement rules. A public hearing is scheduled for November 9, 1999.

Final and temporary regulations under section 1502 of the Code pertain to the operation of sections 382 and 383 of the Code, relating to limitations on net operating loss carry-forwards and certain built-in losses and credits following an ownership change, with respect to consolidated groups.

Final and temporary regulations under section 1502 of the Code relate to certain deductions and losses, including built-in deductions and losses, of members who join a consolidated group. The regulations provide rules for computing the limitation with respect to separate return limitation year (SRLY) losses, and the carryover or carryback of losses to consolidated and separate return years.

Use of actuarial tables in valuing annuities, interests for life or terms of years, and remainder or reversionary interests. Proposed, temporary and final regulations under section 7520 of the Code relate to the use of actuarial tables in valuing annuities, interests for life or terms of years, and remainder or reversionary interests.

Final regulations under section 6038B of the Code relate to information reporting requirements for certain transfers of property by United States persons to foreign partnerships and relate to reporting requirements for certain transfers of cash to foreign corporations.

Final regulations under section 3306(r)(2) of the Code provide guidance as to when amounts deferred under or paid from a nonqualified deferred compensation plan are taken into account as wages for purposes of the employment taxes imposed by the Federal Unemployment Tax Act (FUTA).

Final regulations under section 3121(v)(2) of the Code provide guidance as to when amounts deferred under or paid from a nonqualified deferred compensation plan are taken into account as wages for purposes of the employment taxes imposed by the federal Insurance Contribution Act (FICA).

Temporary, proposed, and final regulations under section 6103 of the Code relate to additions to, and deletions from, the list of items of information disclosed to the Bureau of the Census for use in certain statistical programs.

Temporary, proposed, and final regulations under sections 6221 through 6233 of the Code relate to the unified partnership audit procedure added to the Code by the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA). A public hearing is scheduled for April 14, 1999.

Final and temporary regulations provide changes to the rules under section 411 of the Code regarding qualified retirement plan benefits that are protected from reduction by plan amendment. The changes were made necessary by the Taxpayer Relief Act of 1997.

Final regulations and temporary regulations under sections 865 and 904 of the Code relate to the allocation of loss recognized on the disposition of stock and other personal property and the computation of the foreign tax credit limitation.

Final and temporary regulations under section 6695 of the Code provide income tax return preparers with two alternative means of meeting the requirements that a preparer retain the manually signed (by the preparer) copy of the return or claim.

Final regulations under section 337 of the Code generally affect a taxable corporation that transfers all or substantially all of its assets to a tax-exempt entity or converts from a taxable corporation to a tax-exempt entity in a transaction other than a liquidation, and generally requires the taxable corporation to recognize gain or loss as if it had sold the assets transferred at fair market value.

Final regulations relate to the treatment of certain investment income under the qualifying income provisions of section 7704 of the Code and the application of the passive activity loss rules to publicly traded partnerships.

Temporary and proposed regulations under section 6695 of the Code relate to the due diligence requirements for paid preparers of federal income tax returns or claims for refund involving the earned income credit. A public hearing is scheduled for May 20, 1999.

Final regulations under section 411 of the Code provide guidance on the requirements of section 204(h) of the Employee Retirement Income Security Act of 1974, as amended (ERISA), relating to defined benefit plans and to individual account plans that are subject to the funding standards of section 302 of ERISA.

Final, temporary, and proposed regulations under sections 411 and 417 of the Code relate to the increase from $3,500 to $5,000 of the limit on distributions from qualified retirement plans that can be made without participant consent.

Final regulations under section 7702B of the Code relate to consumer protection with respect to qualified long-term care insurance contracts and relate to events that will result in the loss of grandfathered status for long-term care insurance contracts issued prior to January 1, 1997.

Final regulations under section 6404 of the Code relate to the abatement of interest attributable to unreasonable errors or delays by an officer or employee of the IRS in performing a ministerial or management act.

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